BDI position on the proposal for harmonised classification of titanium dioxide - Position

Page created by Annie Wise
 
CONTINUE READING
Position

BDI position on the proposal for
harmonised classification of
titanium dioxide

Bundesverband der Deutschen Industrie e. V.

 Version: 29 January 2018
Titanium dioxide

Background

Further to a proposal by the French authority ANSES for harmonised
classification of titanium dioxide (TiO2; EC 236-675-5; CAS 13463-67-7) as
probably carcinogenic to humans (category 1B), the competent Committee
for Risk Assessment (RAC) of the European Chemicals Agency (ECHA)
discussed the proposal for harmonised classification and published the
following classification proposal on 12 October 2017:
Suspected carcinogenicity (category 2, on inhalation), labelling with
pictogram GHS08 (health risk), signal word “warning” and hazard statement
H351 “suspected of causing cancer”.
At the meeting of the competent authorities of EU Member States
CARACAL (Competent Authorities for REACH and CLP) on 15-16
November 2017, several Member States lodged reservations against the
classification and indicated a need for further deliberations.
In this position paper, BDI sets out its stance on the proposal for harmonised
classification and labelling of titanium dioxide.

Executive Summary

Classification of titanium dioxide as suspected of causing cancer (category 2,
on inhalation) is not justified!
Rationale: Titanium dioxide does not exhibit any hazardous properties
intrinsic to the substance, it is a non-hazardous solid. All substitutes exhibit
either the same or more critical properties. Hence, substitution with other
substances would not lead to any risk reduction; rather, it would pose
additional risks in most cases. The assessment is difficult to understand from
a toxicological standpoint, leads to great uncertainty among users and has far-
reaching consequences for trade and industry. The legal effects associated
with classification are very serious and entail considerable disadvantages for
end users, industry and traders.
The current discussions on titanium dioxide demonstrate in a striking manner
that the classification criteria urgently need to be adapted to reflect modern     Bundesverband der
scientific criteria.                                                               Deutschen Industrie e.V.
                                                                                   Mitgliedsverband
                                                                                   BUSINESSEUROPE

                                                                                   Hausanschrift
                                                                                   Breite Straße 29
                                                                                   10178 Berlin
                                                                                   Postanschrift
                                                                                   11053 Berlin
                                                                                   Ansprechpartner
                                                                                   Herbert Bender

                                                                                   T: +4916096992653
                                                                                   F: +493020282793
                                                                                   Internet
                                                                                   www.bdi.eu
                                                                                   E-Mail
                                                                                   H.Bender@bdi.eu
Titanium dioxide

A Assessment of the classification proposal
In the eyes of German industry, classification as carcinogenic in a category
within the meaning of the CLP regulation is neither justified nor
appropriate. In addition, such a classification entails serious negative
consequences without delivering any benefit. This overall assessment is
based on the following considerations:

Toxicological starting point and transposability of animal
studies
A possible link between exposure to titanium dioxide and lung cancer was
examined in various major epidemiological studies (cohort studies and
case control studies on employees involved in titanium dioxide
production). In none of the relevant studies could a link be established
between exposure to titanium dioxide and lung tumours. Titanium dioxide
has been used safely for decades, no health risks to humans are known from
practical experience.
The proposal for classification in the CLH report is built essentially around
studies on rats exposed to extremely high concentrations of titanium
dioxide particles which led to so-called “lung overload” effects. The
particle concentrations used in the tests1 were up to 200 times greater than
the workplace limit value applicable in Germany for breathable particles
(alveolar dust) or did not meet the requirements placed on a regulatory
guideline study.
All relevant guidelines from ECHA, OECD and ECETOC establish
unanimously that results from “lung overload” studies on rats should not
be transposed to humans since the relevance for humans is not given. By
comparison with all other species examined, rats are particularly sensitive
to inhalation toxicity through insoluble particles1: only in rats have
tumours in the respiratory tract been identified with insoluble particles.
Other animal species such as mice or hamsters did not develop lung
tumours on comparable exposure. From a toxicological standpoint and
taking into consideration of the criteria in the ECHA guideline,
classification as carcinogenic is therefore not justified.

Exposure situation and protection through existing statutory
rules
The effect of titanium dioxide under examination is based on particle-
related inflammation processes following exposure to and inhalation of
high concentrations of dust triggered by an overload on physiological
lung clearance processes which occurs under such conditions. This is not
substance-specific for titanium dioxide but is characteristic for highly
insoluble substances (bioresistant granular dust) irrespective of the
underlying substance.

1Relevance of the rat lung tumor response to particle overload for human risk assessment—Update
and interpretation of new data since ILSI 2000; D.B. Warheit, R. Kreiling, L.S. Levy
                                                                                                  Seite
www.bdi.eu                                                                                        3 von 16
Titanium dioxide

For the classification of carcinogenic substances, the CLP regulation – like
the Globally Harmonized System of Classification and Labelling of
Chemicals (GHS) on which it is based – requires the existence of an intrinsic
property (CLP regulation, annex I, 3.6.2.2.1, GHS 1.1.3.1.1). RAC did not
establish a substance-specific toxicity. Accordingly, a decisive condition for
inclusion in annex VI of CLP on harmonised classification is not met.
RAC’s position paper does not start from the hypothesis that titanium
dioxide has an “intrinsic” toxicity but advances a general particle property.
The property was assumed for the entire group of PSLT (poorly soluble
low toxicity particles). On the basis of this position, this would mean that
all PSLT would have to be evaluated and treated the same way. Such an
approach makes no sense either from the angle of health protection or
within the meaning of the CLP regulation but leads to wide over-labelling
and, as a result, to a downgrading of risk labelling.
Protection against dust and general particle effects is primarily a matter of
health and safety at the workplace. There are therefore corresponding dust
limit values in Germany and other EU Member States in order to protect
against particle-related lung inflammation processes caused by exposure to
and inhalation of dust. The German general dust limit value (German
abbreviation ASGW) is intended to prevent a deterioration in the
functioning of respiratory organs caused by a general dust effect and
applies for all poorly soluble or insoluble particles. At European level,
exposure to dust could be regulated in a harmonised way via directive
98/24/EC on protection of the health and safety of workers.

Automatic legal effects and consequences of the proposed
classification
In many statutory regimes such as plant safety, environmental and
consumer protection, or in special legislation on toys, food contact
materials or cosmetics, extensive obligations as well as wide-ranging bans
and restrictions arise through classification and labelling as carcinogenic
in category 2, automatically and without further verification as to whether
use of the substance actually poses risks. For instance, toys containing
titanium dioxide would be banned under the EU directive on the safety of
toys. Classification in category 2 as “suspected of causing cancer” would
also have wide-ranging consequences for the labelling of mixtures.
Affected products would have to be labelled with the warning “suspected
of causing cancer”, which would result in considerable uneasiness.
As already called for in BDI’s general position on how to deal with
classifications and their legal effects2, classification decisions must not
lead to a creeping shrinkage in the base of materials available to German
industry. Inasmuch, the classification and its consequences must not be
considered in isolation. The automatic knock-on legal effects in other areas
must always be evaluated in the overall context and, where necessary, at

2
  BDI draft final: Position setting out principles for addressing classifications and their legal effects;
version 9 January 2015
                                                                                                             Seite
www.bdi.eu                                                                                                   4 von 16
Titanium dioxide

least temporarily decoupled so that holistic risk-oriented considerations
can be elaborated in a differentiated way. It follows from this that an
inventory of available use cases with evaluation of the specific risk must
be carried out first.
Industry takes a critical stance in particular on the following consequences
and automatic legal effects associated with the proposed classification of
titanium dioxide:

•    Waste legislation:
     Classification of waste in European waste legislation is based on EU
     chemical legislation. The hazardous properties of waste (so-called “HP
     criteria”) were aligned on GHS at the end of 2014. The HP criteria
     stipulate the point from which the property of hazardous waste obtains.
     The principles for waste classification are set out in the EU waste
     framework directive (2008/98/EU) and in the European waste
     catalogue. If a waste contains a substance suspected of causing cancer
     (category 2) at a concentration of ≥ 1.0%, the waste has to be classified
     as hazardous in accordance with HP 7. As a consequence of this,
     essentially all wastes which contain titanium dioxide at a concentration
     of more than 1% would have to be classified as hazardous and
     processed accordingly. These wastes could range from plastics,
     building materials, wallpapers, paint remnants, speciality papers,
     porcelain crockery and topsoil (depending on geology) through to
     imported coal or furniture. Exceptions would be possible only if the
     wastes in question is unreservedly assigned to a waste heading not
     marked with an asterisk to which, in turn, no corresponding “mirror
     entry” of a waste heading marked with an asterisk is assigned
     (“absolute classification”).
     The associated obligations arising automatically for processing such
     waste classified as hazardous would go hand in hand with numerous
     complications and additional burdens for companies and end users,
     e.g. plant permits in accordance with the 4th decree on implementation
     of the federal emission protection law (4. BImSchV), requirements
     under the decree on provision of proof with substantial documentation
     obligations or notification and release obligations under sub-federal
     legislation as well as requirements on cross-border transport. By
     contrast with the CLP regulation, broadly speaking no provision is
     made for derogations in the HP criteria for waste legislation. It is also
     questionable whether recycling of these wastes would still be possible
     or even sensible, since markets for the recycled material will also
     change as a result of classification. Household or local separate
     collection of recyclable materials as occurs in the German “dual
     system” would no longer be possible in its current form and it would
     also no longer be possible to meet the quotas established nationally (in
     the packaging law) and at European level (in the circular economy
     package).

                                                                                 Seite
www.bdi.eu                                                                       5 von 16
Titanium dioxide

    Disappearance of important quality indicators for
     consumers
     Ecolabels such as Blauer Engel may not be issued for many products
     containing substances suspected of causing cancer (category 2). The
     same applies for the EU ecolabel and for Nordic Swan. As a result,
     important quality indicators for consumers would disappear.

    EU toys directive
     Toys are also affected by a classification of titanium dioxide.
     Substances classified as suspected of causing cancer in category 2 are
     banned in toys and toy components, and placing them on the market is
     restricted under the provisions of the toys directive (2009/48/EC). For
     example, wooden toys, plastic toys with printed stickers or paint boxes
     with titanium dioxide components would no longer be allowed.

•    Air quality standards (TA Luft)
     Point 5.2.2 of TA Luft establishes a direct link between classification
     of a substance in accordance with the CLP regulation and limits on
     emissions to air which are not based on the provisions of the IED
     directive or other European requirements. This linkage can lead to
     disproportionate retrofitting requirements on industrial plant.

•    Classification and labelling of mixtures
     At a concentration above 1.0%, classification in category 2 leads to
     labelling of mixtures with the hazard symbol GHS08 “health hazard”
     and the hazard statement H351 – “suspected of causing cancer”
     (category 2, on inhalation). This classification and labelling leads to
     great uneasiness in the downstream legal areas without taking into
     account that there is no real health risk either for employees and
     private end users or a threat to the environment. It can be assumed that
     acceptance of a substance “suspected of causing cancer” is not a given
     in consumer products. It is therefore highly probable that consumers
     will avoid products labelled as such even though there is no danger.
     Classification of titanium dioxide leads to over-labelling and, as a
     result, to consumer rejection. An evaluation of the real risks by the
     user is no longer possible and this leads to a downgrading of risk
     labelling and the CLP regulation.

•    Use of titanium dioxide as a negative control in studies
     Titanium dioxide has been used as a negative control in many
     inhalation tests in order to assess a range of substances. As a rule, these
     tests have been used in REACH dossiers. Classification of titanium
     dioxide would lead to all relevant animal tests having to be repeated
     with other control substances. However, since the effect is particle-
     related rather than toxicological, as already described, corresponding
     control substances would not be available. Accordingly, the dossiers
     in question would be worthless de facto.

                                                                                   Seite
www.bdi.eu                                                                         6 von 16
Titanium dioxide

Conclusion
The proposal presented for classification and labelling of titanium dioxide
is inappropriate from a toxicological and epidemiological standpoint, the
criteria for classification are not met. All in all, the legal conditions for
harmonised classification do not obtain.
Existing health and safety legislation regulates protection against dust and
particle-related effects not caused by specific substances. Classification
would not contribute to an improvement in protection of health and
environment but would have serious and disproportionally problematic
effects in almost all legal areas, could additionally bring a deterioration in
health and safety at work in its wake and would lead to a downgrading of
risk labelling and the CLP regulation through over-labelling. Were the
Commission to take a decision in this direction, it should be legally
challenged. Affected companies should reserve the right to seek legal
remedies and, where appropriate, claims for damages.
In future, an obligatory risk assessment and impact assessment should be
carried out prior to a proposal for a harmonised classification, involving
manufacturers, importers and users. If no additional measures are
necessary for consumers, employees and environment, work on the
substance should be halted. If a risk is identified in partial areas, the areas
in which there is no risk and no additional measures are needed should be
excluded with a view to proportionality. This would ensure that the
reference rues would not result in any automatic and disproportionate
restrictions and/or bans. The automatic and disproportionate legal effects
of classification of substances urgently need to be corrected. Classification
decisions must not lead to the disappearance of established substances
which are used safely. Since it is evident that the current criteria for
classification of substances lead to flawed classifications, the latter must
be urgently reviewed and adapted to reflect modern scientific knowledge.
Industry as well as all relevant stakeholders should be brought into this
process in timely fashion in order to ensure a transparent review of the
criteria.

B    Importance of titanium dioxide in various industrial sectors
     and socio-economic consequences of the proposed
     classification
Thanks to its excellent properties without a hazardous intrinsic property,
titanium dioxide is an all-round raw material in almost all industrial
sectors. Titanium dioxide is widely used, predominantly as a white pigment
and as a (photocatalytic) coating.
In Germany, primarily pigmentary titanium dioxide is manufactured at five
locations with a total capacity of around 480,000 tonnes. This means that
Germany is the third largest production country worldwide, behind the
USA and China.

                                                                                  Seite
www.bdi.eu                                                                        7 von 16
Titanium dioxide

Lacquer, paint and printing ink industry
Manufacturers of paints, lacquers and printing inks are major customers
for titanium dioxide with a share of 57%. White pigment is far and away
the most important raw material for this industry and is used with a share
of up to 55%, for instance in paints or lacquers. Titanium dioxide is used
above all because of its light resistance, high refraction index and high
diffusion capacity. In coloristic terms, it has the highest opacity of all white
pigments together with an excellent lightening power as compared with
coloured media. In addition, titanium dioxide is heat-stable, non-
flammable, almost insoluble in water as well as resistant to weather and
ultraviolet rays. Of the 2,328 colour shades in the RAL system, just 119
(5%) are produced without titanium dioxide. Hardly any alternatives to
titanium dioxide are available for lacquers, paints and printing inks because
other raw materials are usually of poorer quality, not accessible in the
required volume and additionally often ecologically and toxicologically
questionable. Titanium dioxide is added to paints as a pigment and is then
firmly incorporated in the binder matrix. Therefore, titanium dioxide does
not constitute any danger to humans in paints and lacquers, either at the
workplace or in the use of products containing titanium dioxide.
Classification as carcinogenic (category 2) can be expected to lead to
considerable uneasiness among consumers and reticence with regard to
purchasing. Classification as carcinogenic (category 2) would have the
consequence that paint remnants and building rubble containing titanium
dioxide would have to be processed as hazardous waste. To take just one
example, costs for processing containers used commercially (e.g. by
painters) would increase from 10 million Euro today to 200 million Euro.
Ecolabels such as “Blauer Engel” can no longer be issued in the event of
classification. The consequences for the award of ecolabels for printed
products are currently almost inestimable.
Around 25,000 people are employed in the lacquer and printing ink
industry. Many of these jobs, especially in small and medium-sized
enterprises (SMEs), would be massively under threat if titanium dioxide
were to be classified as carcinogenic, because most companies do not have
their own research and development departments which could undertake
such a comprehensive formula change.

Importance of titanium dioxide for the paper industry
Titanium dioxide has been used as a safe and indispensable white pigment
in paper, pulp and cardboard manufacture for many decades. Titanium
dioxide plays a special role in the production of so-called decorative
papers. These are impregnable speciality papers which serve as the basis
for the manufacture of decorative surfaces for modern furniture and floor
coverings. Thanks to its excellent optical and technological properties, the
share of titanium dioxide in decorative papers can be up to 40%.
Substitution with other raw materials has not yet proved possible and is
also still unforeseeable despite decades of efforts.

                                                                                   Seite
www.bdi.eu                                                                         8 von 16
Titanium dioxide

Around 14% of the annual titanium dioxide demand (1.2 million tonnes) is
needed for the manufacture of decorative papers. The production capacities
for decorative papers in Germany are around 400,000 tonnes a year and
therefore corresponds to just under 30% of world production. In this
segment, 2,000 workers generate around 800 million Euro a year. The
value of the decorative surfaces produced with these decorative papers
across Europe is estimated at around 15 billion Euro a year.

Plastics industry
The main areas where titanium dioxide is used in the manufacture of
plastics are coatings, followed by plastic dyes and laminated papers. In
plastic processing, titanium dioxide is used as a stabiliser, opacifier or
component of colour pigments – mostly after the step of plastic production
in the compounding or when plastic goods are being processed. Titanium
dioxide has asserted itself as the leading white pigment. Its interaction with
light makes it noteworthy for light scattering which leads to opacity or as
absorption of the energy from ultraviolet light in order to protect polymers
against degradation through ultraviolet light. Through classification of
titanium dioxide, a very high share of dyed plastics would become
hazardous waste with corresponding consequences for their reputation in
the public mind and problems with waste treatment and recycling.

Manufacture of pigments, pigment preparations, ceramic dyes
and master batches
Titanium dioxide occupies a prominent position as a raw material in the
area of pigments and pigment preparations. It is used for synthesis of
important inorganic coloured pigments. In this context, titanium dioxide is
completely converted during the manufacturing process and is the
indispensable basis as a structural component in the process for producing
these coloured pigments. Thanks to its excellent opacity, titanium dioxide
is used as the most important white pigment in other pigments, ceramic
dyes, pigment preparations and master batches for the subsequent dyeing
of plastics and paints for artists and students. Depending on the application,
the content of titanium dioxide in pigment preparations range from 1 to
almost 100%, in ceramic dyes from 5 to 60% and in master batches from
0.1 to 80%.
Titanium dioxide is extremely resistant to light and therefore has the
highest opacity of all white pigments in coloristic terms. Given these
excellent material properties of titanium dioxide in combination with
health, safety and ecological properties, none of the alternatives is
anywhere near as useful.

Natural raw materials and ceramics industry
Titanium is the ninth most common element in the earth’s crust at a
percentage of 0.6 by mass. Numerous mineral stone and earth raw materials
contain geogenous titanium dioxide, often in magnitudes of up to several
percentage points by mass, e.g. clay or kaolin. Titanium content has its
                                                                                 Seite
www.bdi.eu                                                                       9 von 16
Titanium dioxide

origin in igneous rock compounded with ore minerals such as rutile (TiO2),
ilmenite (FeTiO3) and ulvite (TiFe2O4) on the one hand and rock-forming
minerals such as amphibole, pyroxene and biotite on the other hand. As a
chemically resistant and abrasion-proof mineral, rutile can be carried over
long distances and deposited in sedimentary rock, e.g. clays. By contrast,
rock-forming minerals weather and the released elements in this process
form new mineral phases. The new mineral phase anatase (TiO2) then
dominates in sediments such as clays. Hence, the titanium dioxide content
in weathered earths can be up to more than 1% by mass, and in titanium-
rich rock can rise to 10% by mass or more. For instance, this can mean for
clay deposits that geogenous titanium dioxide content occurs in
magnitudes of up to 4.5% by mass, compounded in the minerals rutile and
anatase.
Hence, classification of titanium dioxide would have wide-ranging
consequences for the extractive and ceramics industries. Ceramic raw
materials are a cornerstone of industrial production and it is no longer
possible to imagine products made with them being absent from our
everyday lives.
Most products of the ceramics industry manufactured using natural raw
materials have a TiO2 content of over 1% by mass. In other words, the
ceramic material of which the products consist would be classified as
carcinogenic. This can lead to acceptance problems among consumers, in
particular for products which come into contact with foodstuffs, i.e.
crockery. In the case of glazed porcelains, titanium dioxide is found not
only as a component in the raw material but is consciously added to glazes
in order to increase opacity or to achieve a certain colour. The colour range
for decorations on porcelain would be severely restricted without titanium
dioxide (see above). Similarly, ceramic implants (e.g. artificial hips)
contain a share of titanium dioxide which clearly exceeds 1%.
Alternatives to clay-based natural raw materials are hardly available in
practice; ceramic products would have to be processed predominantly as
hazardous waste if TiO2 is classified as intended.

Building materials industry: manufacture of construction
products and chemical construction products
Titanium dioxide is an indispensable ingredient in the manufacture of
construction products or chemical construction products, e.g. for the
formulation of pigmented coatings, fillers, mineral plasters and pastes,
grouts, dry mortars sealants and other visible surface coatings. In the
overwhelming number of use cases, titanium dioxide functions here as a
white pigment. For special applications in the area of construction,
titanium dioxide is sometimes also used as a photocatalytic material for
removal of nitrogen oxides or organic compounds. Innovative construction
materials use these effects to achieve self-cleaning surfaces or
improvements in indoor air quality.

                                                                                Seite
www.bdi.eu                                                                      10 von 16
Titanium dioxide

No alternative ingredients which exhibit comparable properties are
currently known in the area of construction materials. The properties to be
highlighted include in particular the high refraction index (high opacity)
and the whiteness of titanium dioxide. In a historical context, titanium
dioxide has replaced other white pigments such as white lead which, by
contrast with titanium dioxide, attract greater criticism from a toxicological
standpoint.

Steel industry
Titanium dioxide is used in various forms in the steel industry. In oxygen
steel works, it is used in the form of rutile as an alloying agent alongside
ferrotitanium. In addition, rutile is blown into the blasting furnace under
certain conditions in order to ensure safe use. Use in a ladle furnace is also
possible.
As a component of lacquers used to coat metal sheets, a titanium dioxide
content of up to 50% can occur in wet lacquer and the concentration can
be markedly higher once it is baked on. In addition, titanium dioxide can
occur in various raw materials used in the steel industry such as coal and
ore at a natural share of more than 1%. Rutile is also often a component in
welding electrodes.

Glass industry
Titanium dioxide is used in the glass industry, both for the production of
speciality glass and for flat glass. For the manufacture of speciality glass,
titanium dioxide is added to the molten glass and deployed at a
concentration of less than one and up to 30%. In this case of speciality
glass, titanium dioxide was introduced deliberately following intensive
research as a substitute for lead oxide. An example of a product made by
the speciality glass industry with titanium dioxide is constituted by glass
ceramics (Ceran hobs or Robax heating stove windows). In the case of flat
glass production, it is used as a coating for all glass panes in the area of
construction or in dyes.
There is currently no possibility to substitute titanium dioxide, since no
other substance has the same positive properties in glass. Titanium dioxide
has clear effects on the chemical and physical resistance of glass, on light
refraction, ultraviolet absorption, on weight and thickness, crystallisation
behaviour, expansion behaviour, mechanical resilience and on sunscreen
properties as well as the good light performance, anti-reflective coating
and energy efficiency for window glass in the construction and automotive
sectors.

Catalysts in hot gas purification
Titanium dioxide in its anatase modification is widely used in SCR
catalysts for hot gas purification (= selective catalytic reduction). Here,
titanium dioxide is needed for selective catalytic reduction of nitrogen
oxides (NOx) in hot gases (250 – 800°C).
                                                                                 Seite
www.bdi.eu                                                                       11 von 16
Titanium dioxide

Classification of titanium dioxide would have wide-ranging consequences
for its use as a catalyst and hence for effective and economic reduction of
nitrogen oxides in industrial processes and in motorised vehicles (diesel
engines). It is therefore to be feared that classification would also have
negative ecological consequences alongside economic consequences.

Manufacture of cosmetic products
Titanium dioxide is a significant component in the formulation of very
many cosmetic products, e.g. skin protection and skincare products,
sunscreens, toothpastes and decorative cosmetics. Titanium dioxide is
expressly permitted as a colour pigment and ultraviolet filter in the
framework of the EU cosmetics regulation. These permits are based on
thorough risk assessments by the competent independent scientific EU
committee SCCS (Scientific Committee on Consumer Safety). The
nanoscale form of titanium dioxide is currently being re-evaluated
especially for use as an ultraviolet filter in all toxicological end points. In
any event, titanium dioxide is firmly fixed in all cosmetic formulations –
typically in emulsions – so that specifically exposure by inhalation is
generally not relevant for cosmetic products.
Titanium dioxide as an ultraviolet filter pigment is applied as a protective
film on the uppermost skin layer and diffuses and absorbs the sun’s
ultraviolet rays. In this way, the skin is protected against ultraviolet
radiation and its harmful health effects (sunburn, DNA damage, skin
ageing, etc.). Through combination with other filter substances,
particularly high light protection factors can be achieved. In addition,
titanium dioxide stands out for its skin compatibility – intolerances or
allergic reactions to titanium dioxide in cosmetics are almost unknown in
practice.

Pharmaceutical industry
Titanium dioxide has been widely used in the pharmaceutical industry over
many decades for the manufacture of medicines. Among other things,
titanium dioxide is used as a white dye in tablet coatings and capsules
(fixed dosage forms). In addition, it plays an important role in primary
packaging which comes into direct contact with the medicine, e.g. to make
blister packs opaque.

Use in medical products
Various medical products contain titanium dioxide as a pigment in bound
form, e.g. in dental impression materials, dental filling material or dental
laboratory materials and fixing cements. For all these dental materials,
titanium dioxide delivers the best results for maintaining aesthetic colours,
which means that aesthetic dental products can be produced even with a
very low pigment concentration. Furthermore, titanium dioxide is present
in various plastic parts in medical products or medical equipment.
Colouring products white leads to dirt and other impurities being
immediately visible on the one hand and to ultraviolet protection through
                                                                                  Seite
www.bdi.eu                                                                        12 von 16
Titanium dioxide

light resistance on the other hand. Summarising, it can be said that titanium
dioxide provides product stability as well as ensuring hygienic conditions.
Although titanium dioxide has been used for decades not only in medicines
and medical products, there are no known examples of side effects caused
by the substance.

Textile and leather manufacture
Titanium dioxide plays an important role in the area of textile and leather
manufacture. For instance, it is used as:
 Matting agent in chemical fibres, e.g. for white pigmentation of glass
    fibre webbing and polyester
 Component of dyes and coating products, e.g. for HGV and other
    tarpaulins, tents, gym mats, abrasive supports, construction products,
    bellows, decorating bags, technical textiles, sun protection (black-out,
    dim-out)/roller blinds/decorative materials
 Component of printing inks (e.g. inkjet, digital printing) and in pastes
    for pigment printing (e.g. household textiles such as bed linen)
 Support material for biocidal active substances
 Component for pigmentation of leather.
Thanks to its high refraction index, titanium dioxide enables the most
effective white pigmentation with the best possible opacity. This goes hand
in hand with excellent ultraviolet resistance. Through its use in coatings,
titanium dioxide is always bound in a coating matrix and its release is
therefore hardly possible. With its long service life, it is a very sustainable
product. Accordingly, it currently has no alternative for most applications
in the area of textile and leather manufacture.

Manufacture of adhesives
As a component of adhesive formulations, titanium dioxide is widely used
in a very wide range of sectors – from the construction sector, paper and
packaging industry, automotive, rail, ship-building and aeronautics
through to electronics, electrical technology, dentistry and other sectors.
Titanium dioxide is used predominantly in reactive adhesives, dispersion
adhesive pastes and hot melt adhesives.
Despite the relatively high price, adhesive manufacturers use titanium
dioxide as a white pigment almost exclusively in their formulations due to
its unparalleled opacity and high level of whiteness. Thanks to the good
opacity, small quantities of titanium dioxide usually suffice to achieve the
desired colour effect without a strong and unwanted increase in viscosity.

Welding industry
Titanium dioxide plays an outstanding role in the manufacture and
processing of welding additives. It is an essential component in a majority
                                                                                  Seite
www.bdi.eu                                                                        13 von 16
Titanium dioxide

of conventional welding additives and fillers. To a decisive extent, it is
determinant the performance of a wide range of welding processes and
classification of welding additives is therefore used as a reference in the
relevant national and international standards.
Casing materials for rod electrodes used for manual welding contain from
5% (basic electrodes) to 80% (rutile electrodes) titanium dioxide. The
equivalent value for welding powders used in submerged arc welding is 5
to 40%.
Large quantities of wire with rutile are used as a filler material in gas metal
arc welding. For these welding additives, the share in product weight is
between 2 and 8%. Furthermore, titanium dioxide is contained in volumes
greater than 0.1% in drawing agents such as those used in the production
of solid welding wires for gas metal and tungsten inert gas arc welding.
There is no substitute for titanium dioxide in all these products.
Classification of titanium dioxide as carcinogenic in category 2 would
oblige producers and users alike to make cost-intensive changes to the way
welding additives are manufactured and processed in order to comply with
workplace health and safety rules. This would affect a large number of
manufacturing companies such as craft businesses, automotive industry,
construction, mechanical engineers and instrument makers as well as
producers of metal consumer goods.
The welding wastes that is unavoidably generated during the manufacture
and processing of welding additives containing rutile (code 12 01 13)
would then have to be declared as hazardous waste, which would make
continued use much more difficult.
Consequently, avoiding the use of titanium dioxide in the manufacture of
welding additives would result in complete areas of manufacturing
industry being deprived of a basic input material. In the absence of a
substitute, classification would inevitably lead to relocation of production
capacities and hence not only to the loss of many jobs but also to the loss
of core skills in the welding industry.

Further applications
Titanium dioxide is used in numerous other applications in trade and
industry. Further examples of where titanium dioxide broadly cannot be
replaced with adequate substitutes include:
 Abrasives: Titanium dioxide is an intrinsic component of many
    corundum grains where it is mainly present in the form of compounds
    (e.g. Al2TiO5) or dissolved in the crystal lattice. Crystalline titanium
    dioxide can also be contained in a limited volume (< 0.5%).
 Chemical fibres: Titanium dioxide is used as a matting agent in the
    manufacture of chemical fibres.
 Steel and metal processing: Titanium dioxide is contained in
    concentrations from 1 to 20%. Products include lubricants used in cold

                                                                                  Seite
www.bdi.eu                                                                        14 von 16
Titanium dioxide

     forming of rolled wire for the manufacture of various wire types and
     qualities.
    Automotive: All vehicle lacquers contain titanium dioxide as an
     essential pigment.
    Electrical appliances: The housings of most household appliances are
     dyed or lacquered white.
    Mining: Imported coal contains titanium dioxide in fluctuating
     concentrations.

                                                                            Seite
www.bdi.eu                                                                  15 von 16
Titanium dioxide

About BDI

The Federation of German Industries (BDI) communicates German
industries’ interests to the political authorities concerned. It offers strong
support for companies in global competition. BDI has access to a wide
network within both Germany and Europe, to all the important markets and
to international organisations. BDI provides political flanking for the opening
of international markets. It also offers information and guidance on all issues
relevant to industries. BDI is the leading organisation of German industries
and related service providers. It represents 36 sectoral organisations and more
than 100,000 companies with approximately 8 million employees.
Membership is voluntary. 15 federal representations advocate for companies’
interests on a regional level.

Imprint

Federation of German Industries
Breite Straße 29, 10178 Berlin, Germany
www.bdi.eu
Phone: +49 30 2028-0

Contact

Prof. Dr. Herbert F. Bender
Senior Manager
Phone: +49 160 96992 653
h.bender@bdi.eu

BDI document number: D 0910

                                                                                  Seite
www.bdi.eu                                                                        16 von 16
You can also read